Privacy Policy

This policy was last updated on July 14, 2023.

Introduction

At Sonatus, Inc., (“Sonatus”, “we”, “our” or “us”), we respect your privacy. We have implemented this privacy policy (“Privacy Policy”) to explain our data collection and use practices.

For purposes of this Privacy Policy, your use of our web site located at www.sonatus.com and your interaction with our company’s representatives, including your use and/or interaction with any of our products and services, shall collectively be referred to as use of our “Web Site.”

Your use of any of our Web Site means that you have read, understood and accepted the terms of this Privacy Policy.

Our data collection and use practices are expected to evolve and this Privacy Policy shall continue to be the principal source of disclosure about the information that we collect, use and share with respect to our Web Site.

This Privacy Policy pertains to our data collection and use practices for information that we receive from you, from your use of our Web Site or from our trustworthy third-party partners. As further explained below, any personal information that you provide to our third-party partners, vendors, distributors, retailers or other parties is subject to the respective privacy policies of these other parties and not this Privacy Policy.

What Information We Collect

Through your use of our Web Site, we may collect one or more of the following types of personal information directly from you:

  • Your name, title, the name of your employer or the name of your company, your business and/or personal email address, your company’s web site address, phone number, IP address, electronic network activity, pages visited, information to enable you to log in and any other information that you voluntarily provide to us; and
  • Information you provide regarding your marketing preferences or in the course of participating in surveys or other promotional offers.

Children’s Privacy

Our Web Site and marketing are not directed to and Sonatus does not knowingly collect personal information from children under the age of 13. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us by emailing us at privacy@sonatus.com.

Cookies, Web Beacons, and Other Data

We engage commonly used website navigation and information gathering tools, such as cookies and web beacons, to collect information as you navigate our Web Site. We and our affiliates use these cookies or similar technologies to analyze trends, administer our Web Site, track user’s movements around our Web Site, store preference information in our Web Site, serve targeted advertisements, and gather demographic information about our user community.

Cookie Notice

We use cookies across our Web Site to help improve our performance, to enhance the user experience and to support some key site functionality. Which cookies we use, and what we use them for is detailed below.

Cookies and Cookie Types

Cookies are small text files that are stored on your computer by websites you visit. They allow the website to do things such as keep track of your preferences as you move around the site so that the website can personalize pages for you and store little bits of information about your visit for use on future visits. Cookies stay on your computer for varying amounts of time depending on their type and the parameters the website sets whilst creating them.

Cookies come in three different types. The cookies themselves vary very little between the types but their effect and use is different.

First Party Cookies

First party cookies are created by the website you are visiting. They can only be read and used by that website.

Third Party Cookies

Third party cookies are not set by the website you are visiting. They are set by a different organization whose features are being used by the website you are visiting. This is common practice if sites use analytical systems supplied by a third party (as most are) to track the usage and load on their website. These may also be created by embedded content in the web page, a YouTube video for instance, as these need their own cookies to work. A third party cookie may also be used by an advertising provider to track your usage of the website and to customize the adverts you receive. As you move between sites that use the same advertising provider, these cookies can allow the provider to track you across these various sites and gain an insight into your internet usage. This website DOES NOT make use of cookies in this way.

Session Cookies

These enable a website to track your use throughout the site, storing choices you have made and any information you have provided. They are a type of first party cookie that only remain stored on your computer until you close your browser when they are then deleted.

Disabling Cookies

Each browser has settings which allow you to elect not to allow websites to store cookies on your machine. As each browser is a little different, we advise you to check your browser’s help functionality for this option or search for instructions that are specific to your browser. If you choose to disable cookies, some aspects of our Web Site may not function as intended.

How We Use Information About You

We may use the information we collect from you or about you in order to provide you with the following:

  • Where it is necessary for us to enter into a contract with you (including acting upon your request for employment with us) and provide our products and services to you for the duration of the contract, including
    • To assist the transactions that you request.
    • To provide products or services through your use of our Web Site or to respond to your inquiries.
  • To provide the information and results that we promised to deliver in connection with your use of our Web Site, including
    • To communicate important information about the products or services that you are interested in.
    • To assist us in enhancing the quality of our Web Site and to help us learn how our potential customers or end users navigate and utilize our Web Site so that we may deliver a customized and better experience for our potential customers and end-users.
    • To compile statistics and analysis about your use of our Web Site, how and where you are locating and/or accessing our Web Site. These statistics are used only to enable us to provide better customer service, products, features and functionality to you and other customers in the future.
    • To develop a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you.
    • To protect our legal rights and manage the security of our networks and property, including to protect our Web Site from security incidents and abuse.
    • To share your information with third parties in order to prevent fraud, criminal or other inappropriate behavior and protect our business interests and rights, privacy, safety and property, or that of the public.
    • To share your information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain and to enforce the terms of any commercial agreement or our terms and conditions. We will also disclose your information to third parties if the rights of another individual may be violated.
    • To send you certain targeted marketing communications, opportunities, experience surveys and marketing promotions from us or through a third party acting on our behalf that may be of interest to you.
    • To send you messages in order to provide you with time sensitive communications related to your transaction.
  • Where necessary for us to comply with a legal obligation, such as to respond to a request for information from a government authority or other party when we are required by law or in response to legal process, obligation or request.

Security of Your Personal Information

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of your personal information. We maintain organizational, technical and administrative measures designed to protect your personal information within our organization against unauthorized access, distribution, loss, alteration or misuse. Whenever we share your personal information with others, we also insist that they do the same. Your personal information is also only accessible to a limited number of personnel who need access to the information in order to perform their duties and if we share with or receive personal information about you with or from others, all data transmissions are encrypted or otherwise conducted in a reasonably secure manner. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised) please contact us immediately by email at privacy@sonatus.com.

If we provide you with the option to register as a user we shall set up your account using a password-protected code. We will allow you to edit your user registration information by using your user name, email address and password. We strongly recommend that you do not divulge your password to anyone and should we provide you with the ability to register with us, we provide you with instructions on how to select a strong password. You may change your password at any time and all password resets are communicated to you using only the email address that you submitted to us. Also, remember to sign out of your registration account and close your browser whenever you have finished your browser session.

Retention (Storage) of Your Personal Information

We retain your personal information for the minimum period necessary to fulfill our business purposes, as set out below: 

  • Marketing purposes: We retain for a minimum necessary period of time certain of your personal identification so that we may continue to market our Web Site to you.
  • Product and service transactions: We retain for a minimum necessary period of time your personal information associated with any of your registered user accounts with us so long as your transaction with us has not otherwise been expired or terminated.
  • Use of our products and services and customer service related queries: We retain for a minimum necessary period of time the information associated with your use of our Web Site, including information, queries and feedback that you provided to us in connection with your use of our Web Site.
  • Disputes & law enforcement: If we are involved in litigation or a governmental or regulatory investigation, then we keep information throughout the period of litigation or investigation and for a minimum necessary period of time after that. If a settlement means that we have to keep information longer, then we keep information for the period required to administer the settlement. If we provide information to law enforcement agencies, then we keep a record of this for a period of time beyond the end of the investigation.

Who We Share Information With

Our Service Providers and Business Partners

We may share all or some portion of your information with our trustworthy service providers and business partners (1) in order for us to provide you with our Web Site, (2) to enhance the functionality, features and quality of our Web Site, (3) to help us store and host our Web Site, to make it function properly and in a secure manner, (4) to monitor our own systems and operations to maintain their performance and security for the benefit of our customers and their use of the Web Site, (5) to help us complete a transaction with you, to help us attract you to the Web site and become a customer of ours or to fulfill an order, service or delivery request, (6) to produce the data our Web Site is intended to generate for our users and customers, (7) to help us send you notifications regarding our Web Site or to respond to your inquiries, (8) to help us activate, monitor and analyze the data generated by our Web Site and to trouble-shoot and analyze the performance of our Web Site, (9) to provide you with surveys, promotional, advertising or marketing information about our Web Site and to collect information about you especially if you are going to use one of our products or services, and (10) to allow you to receive certain services offered by our service providers or business partners.

We require our third-party service providers to agree to privacy and security policies that are consistent with ours. All of our third party service providers and business partners are restricted from sharing your information with others for any other purposes.

If we seek to sell anything to you, all of the financial payment information will be handled, stored and processed by our payment processor in accordance with the payment card industry data security standards. We will not store, process or transmit any of your financial data on our systems and we will rely entirely on our payment service provider to handle these functions.

Other than as stated in this Privacy Policy, we will only share your information with third parties if you have requested us to do.

Government Authorities

Your personal information may also be shared as needed with government authorities for law enforcement, to respond to a request for information from a government authority or other party when we are required by law or in response to legal process, obligation or request.

Sale, Merger or Change in Control

Your information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of Sonatus’ business or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. We will post a prominent notice on our website for thirty (30) days of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.

Your Choices

We will provide you with reasonable access to information about you in accordance with applicable laws, including by providing you with online access and the opportunity to update your information. To protect your privacy and security, we may take steps to verify your identity before granting access or making changes to information you have provided us. To request access to, or correction, deletion or removal of, information about you, please contact us at privacy@sonatus.com . While we will make reasonable efforts to accommodate your request, we also reserve the right to reject such access requests or to impose certain restrictions and requirements on such requests, if required or permitted by applicable law. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.If you receive marketing communications from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial emails from us by sending your request to us by email at privacy@sonatus.com  or by writing to us at the address given at the end of this Privacy Policy. Please be aware that if you opt out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our offerings, but you may also opt out from receiving such messages by contacting us via email at privacy@sonatus.com.

Third-Party Services

Our Website may contain features or links to websites and services provided by third-parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Web Site. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Web Site. We encourage you to learn about third-parties’ privacy and security policies before providing them with information.

Your GDPR Privacy Rights

If you are a visitor/customer located in the European Union (EU) member countries, the United Kingdom, Iceland, Liechtenstein, Norway or Switzerland pursuant to the General Data Protection Regulation (GDPR) we are the data controller of your personal information. Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you or request from you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

We have been working diligently along with our trustworthy partners to implement an organizational, technical and cooperative framework so that all of your rights are respected and honored by us and our partners with respect to the collection, handling, storing and processing of your data.

Under the GDPR, the moment that we first collect your data, you are afforded various privacy rights, including but not necessarily limited to:

  • The right to know who decided what personal information is being collected from you and the purpose behind doing so
  • The right to know each purpose and legal justification why your personal information is being collected and processed and why collecting and processing it is needed to accomplish the disclosed purpose(s)
  • The identity or categories of all third party recipients who are to receive your personal information
  • The right to know if your personal information is to be transferred out of your EU member country or other GDPR compliant country
  • The right to know how long your personal information will be stored and not to have it stored longer than needed to accomplish the stated purpose
  • The right to access, receive or correct your personal information at any time
  • The right to have your personal information erased (where there is no longer legal or necessary grounds to process or store your personal information)
  • The right to have your personal information transferred to another at any time
  • The right to restrict or otherwise object to, the processing of your personal information at any time where your personal information is not accurate, where the processing is unlawful, where your personal information is no longer needed or where there is no longer good legitimate grounds to process your personal information
  • The right to easily and conveniently withdraw your consent to the collection, handling, storage and/or processing of your personal information at any time and to complain to us and/or the appropriate GDPR “supervisory authorities” if you believe any of your rights are being violated
  • The right to know if you are being “profiled” or “monitored” or if certain decisions are being made automatically based on your personal information
  • The right to know and to have your personal information processed only for the purpose that you had provided explicit affirmative informed consent and not for any other purpose from which was either never disclosed to you or for a purpose which you never provided explicit affirmative informed consent
  • The right to know that all of the personal information that was collected, handled, stored and processed was needed in order to accomplish the purpose that you have affirmatively and explicitly consented
  • The right to know of the consequences should you fail to provide all of the requested data that is being asked of you

While the lawful collection and processing of your personal information is necessary for us to accomplish a stated purpose, enter into a contract for providing our products and services to you, deliver on our contractual promise to provide you with our products and services, perform a task in the public interest, carry out our official authority and/or to perform a legitimate interest, we also strive (where necessary) to always provide you with affirmative options so that you may decide based on informed express consent if you want to have your data processed for a particular purpose. When or if we share your data with third parties, whenever required by applicable laws, we always inform you of the name of or the categories of the recipients of such data. Further, whenever required by applicable laws,, we strive to make sure that all of the opt-in consents that are presented to you are intended to fully inform you whether you want us to process your data, the purpose behind processing your data and who or the categories of who we will be sharing your data with in order to accomplish that purpose. Also, when you provide us with your personal information using our Web Site all of the information that is collected from you is transferred out of your country to the United States so that we may deliver on our contractual promise to provide you with the products and services or other information that you want to receive. See “What Information We Collect” to know about all of the information that we collect from you.

Note that no data about you will be retained by us for a non-legitimate purpose if you are unable to complete the registration or account creation process or if you decide at any time that you are withdrawing your consent. If you withdraw a previously submitted consent, we shall also inform all of our relevant partners that your consent has been withdrawn.

Note also that we have put into place with each of our trustworthy partners certain mechanisms of cooperation, communication and agreement so that your GDPR and PIPL privacy rights are also honored by our partners. Accordingly, should you decide to access, rectify, erase, object to or otherwise transfer any of your data that you submitted to us or any partner or if you wish to withdraw any one or all of your consents, please send your instruction to privacy@sonatus.com and we will act on it promptly.

Please note that if you are an individual located in an EU member country, the United Kingdom, Iceland, Liechtenstein, Norway, Switzerland or mainland China and you have sent to us your personal information unsolicited and not in connection with your use of our products or services, after we have completed our review of your communication, we will appropriately delete your communication, including any personal information that may be contained therein.If you have any questions or concerns about your rights under the GDPR and the PIPL or the steps that we have taken to comply with the GDPR and the PIPL, please contact us at privacy@sonatus.com. We are committed to resolving all complaints concerning our compliance with GDPR and PIPL. In addition, you are entitled to complain directly to the Data Protection Agency located in the EU member state where you reside or the UK Data Protection Agency if you reside in the US.

International Transfer of Information and International Visitors

Our Web Site is hosted in the United States. If you choose to use our Web Site from the United Kingdom, the European Union, mainland China, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.

We may transfer and process your personal information in countries other than the country in which you are resident in connection with storage and processing of data, fulfilling your requests, and operating and providing our offerings. These countries may have data protection laws that are different to the laws of your country. Specifically, our offerings are hosted in the United States, and our subsidiaries and third-party service providers and partners operate in the United States and other countries. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy such as relying on the European standard contractual clauses or Chinese standard contractual clauses, as the case may be.

Changes To This Privacy Policy

As necessary, we will update our Privacy Policy to reflect changes in our privacy practices. If we make any material changes, we will post a notice on our Web Site or as otherwise may be required or permitted by law, prior to the change becoming effective. We encourage you to periodically review our Privacy Policy displayed on our Web Site for the latest information on our privacy practices.

We will archive the old versions of this Privacy Notice for your reference.

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “What Information We Collect” and “How We Use Information About You” above, respectively.

For purposes of the CCPA, we do not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Under the CCPA you have the right to have your personal information erased (subject to certain exceptions) and the right to have your personal information transferred to another at any time.

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “How You Can Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “How You Can Contact Us” below. We will process such requests in accordance with applicable laws.

Additional Clauses for Mainland China Residents

Children’s Privacy: Our Web Site and marketing are not directed to and Sonatus does not knowingly collect personal information from children under the age of 14. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please contact us by emailing us at privacy@sonatus.com.

Marketing Communications: To the extent required by applicable laws, we will only use your personal information for marketing purposes after obtaining consent from you. We will always give you the option to choose not to receive marketing communications from us.

Privacy Rights: If you are a resident of mainland China, you may have the following rights under the Personal Information Protection Law (PIPL) in relation to personal information that we hold about you:

  • Right to access to and copy your personal information;
  • Right to withdraw your consent to processing your personal information; however, the withdrawal will not impact any processing before the withdrawal;
  • Right to require correction or supplementation if it is inaccurate or incomplete;
  • Right to require deletion of your personal information where:
  • such personal information is no longer required to achieve the purpose for which it was collected; 
  • we have ceased to offer the products or services, or the retention period for the data has expired; 
  • you have withdrawn your consent and the processing is based on your consent; 
  • we have processed personal information in violation of Chinese laws or regulations, or in breach of this Privacy Notice;
  • other circumstances provided by Chinese laws or administrative regulations that apply;
  • Right to request us to interpret the personal information processing rules;
  • Right to request us to transfer your personal information to another party designated by you according to Chinese laws; and
  • Any other rights provided under PIPL.

Where we cannot satisfy your privacy requests, we will explain our reasons to you.

Data Transfers: If we transfer personal information to other data handlers (similar to GDPR “data controllers”) or to any overseas data recipients, in due course and to the extent required by the applicable Chinese laws and regulations, we will obtain your separate consent in advance and provide a list of the recipients to whom we transfer personal information, their contact details and details on what, how and why such recipients process your personal information, and the methods and procedures for individuals to exercise their rights under this Privacy Notice to overseas recipients. Should you require such information in the meantime, please contact us at privacy@sonatus.com.

How You Can Contact Us

If you have any questions or complaints regarding this Privacy Policy, please contact us at privacy@sonatus.com.

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